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Exceptional Events. Rob Luschek US EPA Region 6 September 27, 2012. Smoke from fires outside of U.S. Volcano Eruptions. Dust from areas outside of U.S. High Pollen. Fireworks.
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Exceptional Events Rob Luschek US EPA Region 6 September 27, 2012
Smoke from fires outside of U.S. Volcano Eruptions Dust from areas outside of U.S. High Pollen Fireworks Also: Wildfires, Structural Fires, Prescribed Fires, Natural Disasters and the associated cleanup, High Winds, Acts of Terrorism, and more
Data Handling of Exceptional Events These unusual or naturally occurring events effect air quality, but are not reasonably controllable. Often they may effect attainment or maintenance of the National Ambient Air Quality Standards “Treatment of Data Influenced by Exceptional Events” (2007) – ensures proper evaluation of data with respect to its cause, identifies reasonable actions that should be taken, avoids imposing unreasonable planning requirements due to these events, and ensures public disclosure and review
Demonstrations Monitoring Agencies: • Demonstrate the event Affected Air Quality • Show the event was Not Reasonably Controllable or Preventable • Demonstrate the event was caused by Human Activity that is Unlikely to Recur or is a Natural Event • Show a Clear Causal Relationship • Demonstrate there would Not have been an Exceedance But For the event • Show the pollutant levels were in excess of the normal Historical Fluctuations Guidance seeks to clarify requirements necessary for demonstrating an Exceptional Event
EPA Regional Office • Region 6 reviews and makes recommendation on concurrence for each event at each site • Region 6 has received Demonstrations from State and Tribal monitoring Agencies • Region 6 has reviewed High Wind, Wildfire, Central American Smoke, African Dust, and other Demonstrations • Depending on complexity, Demonstration Review can take a couple months to over a year to complete, especially if additional information is exchanged between State and EPA
High Wind Action Plans • Similar to the Natural Events Action Plan (NEAP) • Optional tool that may assist in the implementation of necessary controls more expeditiously than with the normal planning process • During Exceptional Event Demonstrations allows for common ground to verify Not Reasonably Controllable or Preventable • EPA approval is required
